Memorandum submitted by The Association
of Port Health Authorities (F15)

THE ROLE OF THE ASSOCIATION IN RELATION TO
ILLEGAL IMPORTS

1. The Association of Port Health Authorities
represents the interests of Local Authorities and Port Health
Authorities which have responsibilities for sea and airports in
the United Kingdom. It represents the majority of such authorities
and includes all the major sea and airports. The Association acts
as a consultee in respect of new legislation and has, for many
years, held regular liaison meetings with the Ministry of Agriculture,
Fisheries and Food, Department of Health and more recently, Department
of Environment, Food and Rural Affairs and the Food Standards
Agency.

2. The Member Authorities of the Association
have responsibility for the inspection of imported foods and products
of animal origin (POAO) imported from third countries. Through
its Imported Food Committee and Border Inspection Post Liaison
Committee, the Association works to ensure consistency of enforcement
throughout the UK.

ILLEGAL IMPORTS

3. Illegal imports are detected by Member
Authorities both at seaports and airports. Member Authorities
report evidence of regular seizures from passenger baggage at
airports, including considerable quantities of "bush meat"
carried by passengers, generally from West Africa. At the seaports
our Member Authorities report a number of seizures of meat products,
smuggled in consignments of mixed foodstuff. Such illegal imports
generally form part of a larger consignment and are either not
declared or misdeclared on accompanying documentation.

INADEQUACIESIN
CURRENT CONTROLS

4. A major problem at seaports is that although
information on consignments is available, there are serious resource
implications in devanning containers both for Port Health Authority
and Port operators. Costs for consignments of POAO are recovered
from the importer. However, it is less easy to do so for smuggled
consignments. Another problem is that no charges can be made for
checks on consignments of foodstuffs which do not contain POAO.
As a consequence, the Port Health Authority has to resource any
such checks for identifying smuggled items from local taxpayers.

5. Whilst manifests for vessels carrying
cargo from other member states are also checked for foodstuffs,
there is little that can be done to control consignments that
have EU status. Consequently, the UK depends on other member states
having an equivalent regime to enforce controls on imported foods,
and in particular to identify smuggled goods.

6. At airports there are serious problems
encountered by Port Health Authorities when attempting to identify
imported foods. Many of the consignments leave the airport destined
for Enhanced Remote Transit Sheds (ERTS). This happens within
minutes of the cargo being removed from the aircraft. There is
not adequate control at ERTS to ensure that illegal imports are
adequately identified and dealt with.

THE ASSOCIATION'S
RESPONSETOTHE GOVERNMENT
ACTION PLAN

7. The Association supports the Government
action plan but feels that further measures might be adopted to
strengthen controls.

 Prior notification of all foodstuff
to Port Health Authorities. It is a requirement that POAO are
notified in advance to PHAs but this does not necessarily happen
for non-animal origin foods. The frequent smuggling of illegal
meat with other foods is clearly a considerable risk and it would
be of assistance if all consignments of foodstuffs were subject
to mandatory notification.

 Adequate funding needs to be made
available for PHAs to properly tackle the problem. At the moment,
much of the funding for imported food control is met from local
tax.

 The Association seeks a total ban
on personal imports of products of animal origin. Most travellers
do not conform with the legal requirements for personal imports.
If a total ban were put in place, there could be no dispute over
any attempt to smuggle items.

 There should be further work through
the European Commission with other member states to ensure that
illegal imports are detected at the first point of entry into
the European Union.

 Powers should be given to Port Health
Authorities to examine all consignments of imported goods, whether
or not they contain foodstuffs, to enable random checks to be
made for smuggled POAO.

8. The Association convened a meeting on
24 April 2002 for representatives to consider how any potential
additional resources might be used to improve the detection of
illegal POAO, and follow up enforcement action. It was agreed
that the following suggestions should be made to DEFRA:

 Control of funding should be by DEFRA
and could then be targeted at identified problem areas. Teams
of six appropriately qualified officers should be based at the
major sea and airports across the UK and should be able to be
diverted to others areas to respond as necessary.

 The team should concentrate on searching
for food and other consignments, in addition to passenger baggage.

 Government should enhance publicity
on this issue.

 Guidance and/or a code of practice
should be issued to the teams to ensure a consistent approach.